Importer of Record services for companies importing into the United States

See if you qualify

Last updated: October 19, 2026

Drone imports: who holds the Importer of Record role under the Section 232 unmanned aircraft proclamation

Since September 3, 2026, unmanned aircraft systems (UAS), their docking stations, and listed parts entering the United States from any country carry a Section 232 duty of 100 or 25 percent on top of every other duty that applies, with a further class of parts added on February 9, 2027. The party that declares the heading, pays the duty, certifies any partner-country content once that process exists, and keeps the records is the Importer of Record (IOR). This page is for compliance, procurement, and finance leaders at companies that make, distribute, integrate, or operate drones and drone components, in the United States or abroad. It sets out the duties in force, who typically holds the IOR role in a drone supply chain, what that party declares, how valuation works, and what is still pending.

Industrial machinery and components staged for shipment, the kind of equipment whose parts and finished units now fall under a Section 232 duty declared by the Importer of Record

The short version

  • Proclamation 11055 of August 13, 2026, Adjusting Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components Into the United States (91 FR 53699, August 19, 2026), imposed Section 232 duties under 19 U.S.C. §1862 on goods from all countries, effective 12:01 a.m. eastern time on September 3, 2026.
  • Annex I carries 100 percent: UAS with a maximum take-off weight over 25 kilograms, UAS of 25 kilograms or less that have thermal imaging, listed docking station items for use in UAS, and parts of heading 8807 for UAS over 25 kilograms, except parts for UAS for retail delivery use, agricultural use, or sale to the Department of War. Annex II carries 25 percent: UAS of 25 kilograms or less without thermal imaging.
  • Annex III adds 25 percent on the remaining heading 8807 parts for UAS from 12:01 a.m. eastern time on February 9, 2027. Where a part falls under both Annex I and Annex III, only the Annex I rate applies.
  • Products of Japan, South Korea, Taiwan, Switzerland, Liechtenstein, and the European Union are capped at 15 percent including the column 1 rate, and products of the United Kingdom at 10 percent, but only if substantially all the critical components and technology are certified to be products of the United States or those partners. Commerce has not yet published the certification process, and CBP says not to report those headings until further guidance.
  • The duties apply in addition to all other duties, taxes, fees, and charges. Drawback is limited to manufacturing drawback on goods of listed trade agreement partners with at least 85 percent partner content. Covered goods admitted to a foreign trade zone must take privileged foreign status.
  • Companies with an approved onshoring plan may import covered products without the duty during construction, and products of companies on the Department of War’s Blue UAS lists or the FCC’s Conditional Approval List as of September 2, 2026 start the clock on February 9, 2027 instead.

On this page: the duties in force, who holds the IOR role, what the IOR declares, valuation, what changed and what is pending, questions.

The Section 232 duties in force today

The Secretary of Commerce opened the investigation on July 1, 2025 (90 FR 31958, July 16, 2025). The proclamation, signed August 13, 2026 and published at 91 FR 53699 on August 19, 2026, rests on Section 232 of the Trade Expansion Act of 1962, 19 U.S.C. §1862, with Section 604 of the Trade Act of 1974, 19 U.S.C. §2483, for the tariff schedule changes. It creates U.S. note 43 to subchapter III of chapter 99 and seven headings that every covered entry reports alongside its chapter 85 or 88 classification.

HeadingApplies toRate
9903.08.20Enumerated articles not for use in UASNo additional duty
9903.08.21Annex I products, from September 3, 2026100 percent additional
9903.08.22Annex II products from September 3, 2026, and Annex III parts from February 9, 202725 percent additional
9903.08.23Products of the United Kingdom meeting the certification conditionCapped at 10 percent
9903.08.24Products of Japan, South Korea, Taiwan, Switzerland, Liechtenstein, and the European Union meeting the certification condition15 percent combined with column 1
9903.08.25Products under a Department of Homeland Security or Department of War approved onshoring planNo additional duty, heading ends February 9, 2027
9903.08.26Products under a Commerce approved onshoring planNo additional duty

Annex I, 100 percent. UAS with a maximum take-off weight over 25 kilograms under subheadings 8806.24.00, 8806.29.00, 8806.94.00, and 8806.99.00; UAS of 25 kilograms or less that incorporate thermal imaging under 8806.21 through 8806.23 and 8806.91 through 8806.93; static converters of 8504.40.9580 and control boards and panels of 8537.10.9170 when for use in UAS docking stations; and parts of 8807.10, 8807.20, 8807.30, and 8807.90 for UAS over 25 kilograms, except parts for UAS for retail delivery use, agricultural use, or sale to the Department of War.

Annex II, 25 percent. UAS of 25 kilograms or less without thermal imaging under the same six 8806 subheadings.

Annex III, 25 percent from February 9, 2027. Parts of heading 8807 for UAS that are not already in Annex I.

The annexes are written in tariff lines, not in component names. Motors, speed controllers, and lithium-ion batteries appear in the proclamation’s findings as examples of foreign dependence, but they are not covered lines today. Clause 5 lets the Secretary of Commerce add components by Federal Register notice; as of October 19, 2026, none has been added. The Rates of Duty 2 column carries the same additional rates, so goods of column 2 countries are covered, and the proclamation names no country: the scope is all origins.

CBP’s filing guidance is CSMS #69738151 of September 2, 2026. It requires one of the 9903.08.20 through 9903.08.26 headings on every entry of chapter 85 or 88 goods within the scope, with 9903.08.20 for enumerated goods that are not for UAS use, and it states that antidumping, countervailing, and other duties continue to apply.

Who holds the Importer of Record role in a drone supply chain

On every formal entry one party is named as Importer of Record. Under 19 U.S.C. §1484 that party must be the owner or purchaser of the goods, or a licensed customs broker they designate, and it carries the duty, the bond, the records, and the reasonable care obligation. In drone trade the role sits in one of three places.

The foreign manufacturer, selling delivered duty paid or into United States stock

The producer enters the goods in its own name as a nonresident importer under 19 C.F.R. §141.18, with a resident agent and a bond from a resident surety. It owes the 100 or 25 percent duty on the full customs value of its own shipments, declares the take-off weight class and the thermal imaging feature that decide the annex, and keeps the certification file if it claims a partner rate once that process exists.

The United States distributor, integrator, or operator

A dealer, a systems integrator, a public safety agency’s supplier, or an enterprise fleet operator buys the goods and enters them. The declared value is its purchase price, or a related party price where the manufacturer is an affiliate, and it is this party that selects the Chapter 99 heading, documents any onshoring approval, and answers a CBP request for the records behind each claim.

A United States Importer of Record provider

Where neither the producer nor its customer holds the role, a United States company with the right to make entry is named on the entry under a shipment-specific authorization. The provider holds its own IOR number, bond, and records, and it must be able to support the classification, the annex determination, the origin, and the value on every line.

Which party holds the role decides who carries a duty that now exceeds the price of many of the goods it attaches to. The who needs a United States Importer of Record page compares the situations side by side.

What the Importer of Record declares on a drone entry

Each of these is a declaration in the IOR’s name, and each turns on a fact in the IOR’s own file:

  • The chapter 85 or 88 classification and the matching 9903.08 heading, including 9903.08.20 for enumerated articles that are not for UAS use
  • The maximum take-off weight class, over or under 25 kilograms, and whether a UAS of 25 kilograms or less incorporates thermal imaging, which together decide Annex I or Annex II
  • For heading 8807 parts, whether they are for UAS over 25 kilograms and whether the retail delivery, agricultural, or Department of War exception applies, and from February 9, 2027, the Annex III rate on the rest
  • The country of origin of each line, because the partner caps attach to products of the listed partners and the certification condition on critical components and technology will attach to the same lines once Commerce publishes the process
  • Any approved onshoring plan and the heading it supports, with the approval on file
  • For goods admitted to a foreign trade zone, privileged foreign status under 19 C.F.R. §146.41, and for any drawback claim, the manufacturing drawback basis and the 85 percent partner content
  • The order of Chapter 99 headings on the line, since the Section 232 duty is in addition to Section 301, antidumping, countervailing, and any other duty on the same goods

Valuation decides the duty

The additional duty is ad valorem on the full customs value, so a 100 percent rate doubles the entered value as a duty bill and a 25 percent rate adds a quarter. Customs value follows the sequential hierarchy in 19 U.S.C. §1401a: transaction value, the price actually paid or payable, comes first, with statutory additions for assists such as tooling or software supplied to the manufacturer, royalties tied to the sale, and packing. Where the seller and the IOR are related, the price must be shown to be unaffected by the relationship or the next method in the hierarchy applies. On drone entries the common questions are whether firmware, ground control software, and accessories invoiced separately form part of the price of the aircraft, and how a bundled kit is apportioned across lines that carry different rates. The customs valuation page walks through the hierarchy.

What changed in 2026 and what is pending

  • July 1, 2025. Commerce initiated the Section 232 investigation into imports of unmanned aircraft systems and their parts and components.
  • August 13, 2026. Proclamation 11055 signed; published August 19 at 91 FR 53699.
  • September 2, 2026. CBP CSMS #69738151 issued. Companies on the Blue UAS Cleared List, the Blue UAS Framework, or the FCC Conditional Approval List on this date receive the delayed start.
  • September 3, 2026. Annex I and Annex II duties in effect.
  • About December 11, 2026. The Secretary of Commerce is to report to the President within 120 days on the effect of the measures.
  • February 9, 2027. Annex III parts duty begins, the delayed start for listed companies ends, and heading 9903.08.25 terminates.

Pending as of October 19, 2026: the Commerce certification process for the partner caps, the onshoring plan procedures and any approved list, any component additions under clause 5, and any amendment. None has been published. CBP’s instruction for headings 9903.08.23, 9903.08.24, and 9903.08.26 is not to report duties under them until further guidance.

See if your shipments qualify

Tell us what you import, which headings your entries are filed under, and who holds the Importer of Record role today. We reply to your work email within one business day. The full form has room for more detail.

Where do you stand (inline form)

Frequently asked questions

Are consumer and prosumer drones under 25 kilograms covered?

Yes. UAS of 25 kilograms or less fall under Annex II at 25 percent, or under Annex I at 100 percent if they incorporate thermal imaging. The weight class and the thermal imaging feature are the two facts that decide the rate.

Does the duty apply to drones from Japan or the European Union?

Yes, with a cap. Products of Japan, South Korea, Taiwan, Switzerland, Liechtenstein, and the European Union are capped at 15 percent including the column 1 rate, and the United Kingdom at 10 percent, but only where substantially all the critical components and technology are certified to be products of the United States or those partners. Until Commerce publishes the certification process, CBP’s guidance is not to report those headings.

Are motors, batteries, and flight controllers covered?

Not as tariff lines today. The covered parts are those of heading 8807 for UAS, plus the two docking station items. The proclamation authorizes the Secretary of Commerce to add components by Federal Register notice, and none has been added as of October 19, 2026.

Does the Section 232 duty stack with Section 301 duties on goods of China?

The proclamation states the duties apply in addition to any other duties, taxes, fees, exactions, and charges, and CBP’s guidance confirms antidumping, countervailing, and other duties continue. The proclamation does not name any specific other program.

Can a foreign drone manufacturer be its own Importer of Record?

Yes, as a nonresident importer under 19 C.F.R. §141.18, with a resident agent for service of process and a bond from a resident surety, and with its own IOR number carrying accurate Form 5106 data. It then owes the duty on its own entries and holds the records. The alternatives are the United States customer or a United States Importer of Record provider.

Related

Sources

This page summarizes publicly available federal actions for general information. It is not legal advice. Requirements are subject to rulemaking and change. Verify current requirements against the Federal Register and CBP guidance.

See if you qualify

Tell us what you import and how your entries are filed today, and we’ll show you where you stand.

See if you qualify